IR 05000312/1988007
| ML20151Q109 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/29/1988 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| Shared Package | |
| ML20151Q111 | List: |
| References | |
| EA-88-173, NUDOCS 8808110038 | |
| Download: ML20151Q109 (3) | |
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UNITED STATES
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N NUCLEAR REGULATORY COMMISSION
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REGION V
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1450 MARIA LANE, SUITE 210
$ ' ' %/%....,o'g WALNUT CREE K, CALIFORNI A 94596 JUL 2 91988 Docket No. 50-312 EA 88-173 Rancho Seco Nuclear Generating Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr. J. F. Firlit Chief Executive Officer,
..wr Gentlemen:
Subject:
Notice of Violation (NRC Inspection Report Nos. 50-312/88-07,50-312/88-08,50-312/88-20 and 50-312/?8-22) EA 88-173 This letter refers to the special inspections conducted on February 5 and 8, 19J8, March 7-11 and 22, 1988, and June 17, 1988.
The inspections included a review of events associated with an occupational dose to the skin of the whole body that was in excess of the regulatory limit.
NRC letters to you dated March 5, 1938, April 22, 1988, and June 23, 1988 transmitted the reports doctenenting the inspections. The inspcctions
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identified four examples of failure to comply with NRC requirements. During
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l the Management Meeting of March 16, 1988 and the Enforcement Conference of July 7, 1988, we discussed with you our concerns about the apparent violations and the other inspection findings. Our report of the Enforcement Conference was sent to you on July 13, 1988.
l The violations described in the Notice of Violation, enclosed herewith as Appendix A, involve (1) an occupational dose to a small area of skin behind a worker's knee that was in excess of the regulatory limit, (2) a failure to
l notify an individual in writing of his exposure at the time the
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Coninission was notified of his exposure, (3) a failure to properly instruct I
individuals in precautions and procedures for minimizing exposures when i
performing work in a "Hot Particle Zone", and (4) a failure of certain individuals to adhere to procedures for the control ct personnel radiation l
i exposure.
Violation A involving the hot particle exposure could individually be classified at a Severity Level III because the exposure exceeded the regulatory limit.
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However, the health implications of this exposure may not rise to this severity level due to the small area of the skin involved. Nonetheless, the violations in their aggregate, as described in the Notice, are of particular concern to the NRC because they demonstrate a lack of management oversight with regard to I (
communications, training and implementation of the procedures of your Hot Particle Program (HPP). Therefore, in accordance witn the "General Statement l
of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
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8808110038 880729 PDR ADOCK 05000312 G
PNU
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Sacramento Municipal Utility District-2-JUL 2 91988 Appendix C (1988) (Enforcement Policy), the violations described in the enclosed Notice have been classified in the aggregate as a Severity Level III violation.
A civil penalty is normally proposed for a Severity Level III violation.
How-ever, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, I have decided that a civil penalty will not be proposed in this case because: (1) you promptly identified and reported the event to the NRC, (2) you took prompt and extensive corrective actions to prevent recurrence, (3) while you had prior notice of a potential problem, we recognize that at the time of the event, you were in the process of implementing a HPP in response to industry problems as described in NRC Information Notice No. 87-39, and (4) that hot particles had not been a problem at Rancho Seco prior to the event of February 4, 1988.
Nonetheless, we emphasize that any similar violations in the future may result in additional enforcement action.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice in preparing your response.
In your response, you should document the specific actions taken to correct the violations and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will detennine whether further enforcement action is recessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of th( Office of Management and Budget as required by the Paperwerk Reduction Act of 1980, Pub. L. No.96-511.
Sincerely, u$
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o gional inist Enclosure: Notice of Violation cc: w/ enclosure:
Public Document Room (PDR)
Nuclear Safety Information Center (NSIC)
State of California J. Vinquist, SMUD S. L. Crunk, SMUD
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Sacramento Municipal Utility District JUL 2 91988 Distribution
'PDR LPDR SECY CA JTaylor, DEDR0
- JMartin, RV JLieberman, OE JJohansen, OE LChandler, OGC Enforcement Coordinators RI, RII, RIII, RIV, RV BHayes, 01 SConnelly, OIA EJordan, AE0D TMurley, NRR EA File ES File State of California
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DCS bec w/ enclosure:
project inspector resident inspectoe G. Cook
B. Faulkenberry J. Martin A. Johnson T. Foley, NRP,
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M. Smith J. Zollicoffer docket file
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